Modern Slavery Statement for the Year Ending 31 March 2025
Download the statement in full.
Commitment
Clearway (2021) Holdings Limited and its subsidiaries (“Group” or “us” or “we”) are committed to operating ethically and with integrity. It is our priority to improve our practices to combat slavery and human trafficking in our business and our supply chain. This statement sets out the steps we are taking to enhance our anti-slavery and human trafficking practices.
This statement is made in accordance with Section 54 of the Modern Slavery Act 2015. It sets out the steps that we have taken to identify and reduce the risk of modern slavery occurring within our supply chain and business operations. The statement refers to the period between 1 April 2024 and 31 March 2025.
Organisation
We are one of the leading UK companies of vacant property security, safety and analytics, highways CCTV, mobile security devices and monitoring services to commercial customers. Our Group’s head office is Penway Place, London. The Group consists of app. 19 independent companies with a total workforce of circa 542 employees. We operate in England, Scotland, France, Germany, Austria and Switzerland.
Our business
The Group operates via independent companies, which enter into contracts in their own capacity and manage their own operational activities, supported by Group level policies and compliance oversight. The Group continues to improve visibility of its supply chain and to strengthen its compliance processes across all business units.
Our supply chain
The Group spends circa £40m a year with suppliers and sub-contractors, giving business to thousands of SMEs across the countries where we operate. Our suppliers and subcontractors deliver a broad range of goods and services such as electronic equipment, uniforms, components for our CCTV towers, or temporary labour. Our risk assessment process has identified a small number of key categories as potentially higher risk of exposure to modern slavery. Those are:
(a). temporary low-skilled or unskilled labour, where labour exploitation risks may arise in certain labour markets; and
(b). manufacture of electronic equipment and uniforms, where production may take place through complex international supply chains.
These areas are therefore subject to greater scrutiny during supplier onboarding and contract negotiations.
Governance and oversight
Responsibility for oversight of modern slavery and human trafficking risks sits with the Group Legal and Compliance function, which supports the Group companies in implementing relevant policies and contractual protections.
The Group Legal periodically reviews compliance with relevant legislation and policies, and the Board of Clearway (2021) Holdings Limited retains overall responsibility for ensuring that the Group operates in accordance with its legal and ethical obligations.
How we manage modern slavery
During the reporting period the Group continued to develop its internal controls aimed at identifying and mitigating the risk of modern slavery.
In particular:
- Risk assessment forms were developed and rolled out across business units to identify potential areas of vulnerability within the supply chain.
- Sub-contractors are expected to deliver their goods and services under Clearway’s standard subcontractor terms, which include provisions addressing compliance with applicable laws and ethical labour practices.
- Supplier terms are reviewed where necessary to ensure alignment with our policies and contractual requirements.
- Higher-risk suppliers may be subject to additional enquiries or due diligence before engagement.
The Group continues to develop its processes to improve supply chain transparency and risk monitoring.
To ensure a high level of understanding of the risks of modern slavery and human trafficking, we provide training to all our staff on modern slavery, money laundering and ethical behaviour. Training forms part of the Group’s broader compliance and ethical conduct framework and is designed to help employees recognise indicators of exploitation and understand how concerns can be reported. In the UK, 97.3% of assigned employees undertook the Modern Slavery training in the reporting period. We are in the process of rolling out relevant training in other territories we operate in.
Our policies
The Group maintains a number of policies designed to promote ethical conduct and prevent exploitation. The policies are well embedded in the UK and we are working on rolling out the same in other jurisdictions we trade in. Our Anti-Slavery and Human Trafficking Policy set out our responsibilities, and those working for and on our behalf, in observing and upholding our position on modern slavery and human trafficking. It also provides information to those working for and on our behalf on how to identify and report concerns regarding modern slavery and human trafficking.
Our Ethics Policy outlines our values and expectations for ethical behaviour. It serves as a guide for all persons working for the Group to ensure actions align with the Group’s mission and legal obligations. The policy addresses conflicts of interest, proper conduct, compliance, and reporting unethical behaviour.
We have established robust recruitment processes in line with relevant employment legislation, including ‘right to work’ document checks, contracts of employment and checks to ensure everyone employed is 16 and above. We only employ agency workers through reputable employment agencies that adhere to our anti-slavery and human trafficking policy.
Our Whistleblowing Policy encourages staff to report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected. Provide staff with guidance as to how to raise those concerns, and reassure staff that they should be able to raise genuine concerns without fear of reprisals, even if they turn out to be mistaken.
Effectiveness of Our Actions and Further Steps
The Group monitors the effectiveness of its modern slavery prevention measures through a range of internal controls and compliance activities. These include implementation of supplier risk assessment forms, inclusion of contractual protections within supplier and subcontractor agreements, staff training and awareness initiatives, whistleblowing reporting mechanisms.
To date, the Group has not identified any confirmed instances of modern slavery within its operations or supply chain.
The Group will continue to review the effectiveness of its actions annually and make adjustments where necessary.
The Group remains committed to continuously improving its approach to preventing modern slavery and human trafficking.
During the next reporting period we intend to:
- further strengthen supplier due diligence processes
- continue the rollout of risk assessment tools across business units
- improve visibility of supply chains where possible
- continue employee training and awareness initiatives
These steps form part of our ongoing commitment to ethical business conduct and responsible supply chain management.
